When an employee requests extended medical leave, employers often wonder how long they must wait before it is no longer “reasonable.” The Fourth Circuit recently addressed this in Coffman v. Nexstar Media, offering clarity on the limits of leave as a reasonable accommodation under the ADA and the interplay with state disability discrimination laws.
Case Summary: Coffman v. Nexstar Media
Leanna Coffman worked as an account executive for Nexstar Media’s news station in West Virginia. In 2021, she became pregnant with twins and was diagnosed with a serious condition requiring bed rest. Nexstar approved her request to work remotely during the final eight weeks of her pregnancy. After delivering via c-section in February 2022, Coffman began a 12-week FMLA leave.
Shortly into her leave, Coffman discovered she had suffered an injury during the c-section, which severely limited her mobility and required multiple hospital visits. In early April, Nexstar reached out to inquire about her recovery. Coffman explained she was still in and out of the hospital and anticipated needing surgery. She claimed to have discussed remote work as a possible accommodation, though Nexstar disputed that such a conversation occurred.
As her FMLA leave neared its end, Coffman transitioned to short-term disability benefits. The benefits were originally set to run until June 27th, but by June 28th, Nexstar had yet to receive a doctor’s return-to-work approval. HR contacted Coffman to check in and Coffman confirmed she was unable to return to work and her short-term disability benefits were being extended. When HR noted that the disability benefits do not extend her FMLA leave (i.e., job-protected leave), Coffman asked if HR wanted to speak to her lawyer. Following their call, Coffman texted the HR assistant, asking Nexstar not to contact her directly and referred them to her attorney.
By late July, Nexstar sent a formal letter requesting a return-to-work date. Coffman responded that she remained under intensive care, had an upcoming surgery requiring six weeks of recovery, and likely needed another procedure in October. She still did not provide a projected return date. Nexstar had allowed Coffman to take an additional twelve weeks of leave after her guaranteed initial twelve weeks of FMLA leave expired. Nexstar, citing the critical nature of her role and the prolonged uncertainty, terminated her employment via email.
Coffman sued under the ADA and the West Virginia Human Rights Act, alleging disability discrimination and under the FMLA for retaliation. The court sided with Nexstar, finding that Coffman’s leave had become indefinite and that she was no longer a “qualified individual” under the ADA. A “qualified individual” is a person who is “able and competent, with reasonable accommodations, to perform the essential functions of the job in question.” Her refusal to provide a return date or engage meaningfully in the interactive process undermined her claims.
Key Takeaways for Employers
Indefinite Leave Is Not Reasonable. The ADA requires accommodations to be reasonable and effective. When an employee cannot provide a projected return date, the leave becomes indefinite—and courts consistently find that such requests exceed the bounds of reasonableness.
Employers Are Entitled to Clarity. The interactive process under the ADA is a two-way street. Employers must engage in good faith, but employees must also provide sufficient medical information and a timeline for return. Without this, employers are not obligated to continue holding the position.
Remote Work Isn’t a Cure-All. While remote work can be a reasonable accommodation, it must be feasible and consistent with the employee’s ability to perform essential job functions. In Coffman, the employee was medically unable to work in any capacity, making remote work irrelevant.
The Interactive Process Has Limits. Employers must initiate and participate in the interactive process, but they are not required to continue indefinitely when the employee is unable to work or refuses to engage. Documenting efforts to communicate and accommodate is critical.
State Laws May Impose Stricter Standards. While the ADA applies to employers with 15+ employees, many state laws—including Ohio’s—apply at lower thresholds. In Ohio, employers with as few as four employees are subject to disability discrimination provisions under the Ohio Civil Rights Act, meaning they may be required to engage in the interactive process even if they fall below the federal ADA’s 15-employee threshold. Employers should be aware of state-specific obligations that may trigger earlier or broader coverage.
Final Thoughts
The Coffman decision reinforces that employers are not required to hold positions open indefinitely. While compassion and flexibility are important, so is operational continuity. Employers should:
- Document all communications regarding leave and accommodation.
- Engage in the interactive process in good faith but recognize when it has reached a natural conclusion.
- Train HR and managers on ADA obligations, including how to distinguish essential job functions, evaluate what accommodations are reasonable, and assess undue hardship.
